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ENERGY STAR Small Network Equipment Draft 1 Comment

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ENERGY STAR Small Network Equipment Draft 1 Comment ENERGY STAR Small Network Equipment Draft 1 Stakeholder Comments and EPA Response Index Comment EPA Response # The immediate effective date cannot be implemented in EU. The EU will require some EPA will work with the EU to incorporate small network equipment into the current agreement as 1 months, to allow for the appropriate administrative processes before the specification can necessary. EPA believes it acceptable for the EU effective date to follow the effective date in the US. come into effect. A normal design cycle would require a minimum of 1 year to make product available, the The specification is intended to identify efficient products that are currently in the market. There are 2 Effective date needs to be more than a year out plus a reasonable transition period to products on the market that can meet the levels set forth in the specification. When other models have product meeting the requirements. 18 to 24 months is appropriate for the market. that meet the requirements become available they can be certified as ENERGY STAR as well. The exclusion for products with SFP sockets will encompass a broad range of products. There needs to be a manner for such products to be included as part of a program. There are two possible solutions: Products with fewer than 12 ports including SFP sockets would have to be explicitly EPA requests specific examples of products using SFP sockets to determine whether these products 3 included in the LNE program. This may be problematic, given different approaches in that should be covered in Version 1.0, or the upcoming LNE specification. program. Products with SFP uplinks could be included, but the SFP port will be disabled during testing and will not be counted in any power allocation equations. The exclusion specifies SFP sockets, but does not mention other pluggable module types. EPA requests input on specific examples of "other pluggable interfaces" that would be considered 4 under this approach. Proposed solution: Add “or other pluggable interfaces.” [Our organization] believes that, notwithstanding the increased use of Integrated Access Devices, standalone Cable and DSL modems will remain a large part of the small network equipment marketplace. Recently published CEA data shows an installed base of over 46 million standalone broadband modems. 5 EPA appreciates feedback on this market. For many of these consumers, standalone broadband modems acquired at retail or leased through their broadband Internet service provider will continue to be the solution that best meets their needs. Enterprise networking equipment is designed to operate in much larger networks with significant security and robustness requirements. As a result, such devices must support larger numbers of addresses, strong security features and traffic that uses these features with sustained high‐throughput data. All of these features require hardware that Data on specific devices and suggestions on how to improve the distinction between SNE and LNE is 6 necessarily draws more power and makes it problematic for such devices to meet the welcomed. same energy requirements as consumer equipment. Implementing the program without distinction between the two types of equipment will cause problems for many organizations that could be barred from using networking equipment that is appropriate to their needs. Page 1 of 14 ENERGY STAR Small Network Equipment Draft 1 Stakeholder Comments and EPA Response Index Comment EPA Response # 1.F.5 – please add “electrical wires” since for example, HomePlug is a LAN technology HPA interfaces are no longer engaged during the testing described in the Test Method. Accordingly, 7 using electrical wires no change will be made to the referenced language. Definition of SNE in 1.A.2. with “a) integral wireless capability” and “Product Types” will inadvertently draw in many STBs, televisions and any device that supports, for example IEEE 1905, as those devices may contain multiple interfaces, one of which may be wireless. The multiple interfaces may be used for redundancy and aggregation of data traffic and thus may bridge or switch data traffic. The primary function of a Set-top Box is sufficiently different from the definitions included for network 9 “Products Types” does not have a specific list, in for example, 2.1.1 but it seems to be equipment that scope conflicts are not anticipated. listed in Table 1. On line 232, recommend changing first sentence of 2.1.1 to “Products that meet one of the following Small Network Equipment Product Type definitions…” Also, the definition of 1. F.1 End Point Device tries to exclude set‐top boxes and IP televisions but has a caveat that the devices are a “originator or destination for network traffic”. Recommend changing to “A device that functions as either an originator, mesh point or destination for network traffic.” EPA believes that the Access Point Definition, in conjunction with the other product type definitions, is 10 Definition in 1.B.2.a ‐ the use of the word "primary" may be a big loop hole sufficiently effective in separating product classifications. 1.F.3 Link Rate ‐ what is meaning of raw? Layer 1 or Layer 2 or ?. It seems to imply Layer EPA thanks the stakeholder for this input and has replaced "raw" with "PHY" in the Link Rate 11 1 or Phy rate. Recommend changing “raw” to “Layer 1 or PHY” definition. 1.F.5.b Coaxial cable ‐ does that include cable modems? Do it mean mean MoCA and EPA's intention is that the language refers to physical ports, not usage. As such, the recommended 12 Ethernet over coax? Perhaps it should be explicitly stated that DOCSIS interfaces are modification will not be made. excluded. For VoIP technology embedded in Network Equipment, EPA welcomes power consumption data. Recommend adding Voice Telephone Port as these parts are available today in products. Such data will be required to address the comment further. 14 Additional power is required to support this feature Of note, EPA has launched an effort to cover VoIP Telephones in the Telephony specification. [Our organization] believes that, given rapid changes in wireless technologies, the definition of "Access Point" needs to be expanded to include more than just 802.11 (Wi- Fi) EPA plans to keep the scope of Version 1.0 limited to the products where data is sufficiently-available connectivity. In particular, [Our organization] proposes that "Access Point" be defined to 15 to support development of appropriate requirements and criteria. At this time, data is not available in mean: the dataset to support review of the other technologies noted in the comment. device that provides, as its primary function, connectivity to multiple clients via IEEE 802.11 (Wi-Fi) or any other wireless interface, including, but not limited to, Bluetooth, Z- Wave, Zigbee, and GSM." Page 2 of 14 ENERGY STAR Small Network Equipment Draft 1 Stakeholder Comments and EPA Response Index Comment EPA Response # The term “wired” is used throughout the document. “Wired” sometimes seems to be a euphemism for Ethernet since the term “ports” often occurs in the same sentence. In other cases, the term “wired” seems to refer to the general case of technologies 16 The existing language seems to be sufficiently clear for products in scope. connected via cabling. Other wired LAN technologies such as HomePlugAV, MoCA , etc have a single cabled port but can connect to several devices. In cases where “wired” actually means “Ethernet”, replace with “Ethernet.” It should be made clear whether varying numbers of ports or different speeds of port While such approaches do not appear appropriate based on the Adder structure in Draft 1, EPA is 17 would be considered acceptable variations between members of a family. open to feedback on how worst-case testing procedures might be implemented. For this initial version exclude Network Equipment that contain hardware circuits that support Internet or Ethernet security or data security functions. Internet/Etherent Security Functions EPA is aware of small network equipment (SNE) products that contain at least a subset of these • Firewall features and requests data that shows that these features should not be included in the scope of 18 • Virtual Private Network (VPN) Version 1.0. EPA believes the non-rack mounted requirement in the SNE definition provides sufficient • Secure Socket Layer(SSL) separation between SNE and large network equipment. • IPsecPacket inspection (different levels) • Encryption/Decryption • Email filtering • And etc… The purpose of ENERGY STAR program is to provide quantifiable efficiency results to consumers. These consumers do not necessarily go deeper to understand what is and what is not applicable or in scope. When this was first announced a couple years ago, requests for ENERGY STAR status were received by Sonicwall sales and customer service departments. It is not possible to determine what the affect on sales was, but the fact that there are calls indicates interest and desire to make purchasing judgments. For EPA welcomes examples of the products in question to allow for evaluation on fit within the stated every call received there will be many more potential customers looking at whatever 19 program scope, and data to provide information on the additional power consumption of these documentation they can find and then making purchasing judgments. All Sonicwall security features. products except for the very low end AP have dedicated security hardware circuits and should be measured over limits specified by Draft 1, version 1.0 from EPA. The way Draft 1 Version 1.0 ENERGY STAR Small Network Equipment (SNE) specification is written it is a Non-Security standard. From the Webinar it is clear that criteria are going to be developed and added at some point. But it is not there now so it must be clearly stated as not applicable products with security functions.
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